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1
Import Manual
4300 New Getwell Road
Memphis, Tennessee 38118
Revised: October 12, 2012
Fred’s Incorporated Mission: “To be the hometown discount store that provides a
Fast, fun and friendly low-price to shop”
2
TABLE OF CONTENTS
Chapter 1 – Introduction and Company Background
Background
Company Information
Company Organization
Company Import Compliance Policy
Purpose of Import Manual
Chapter 2 – Import Process
Ocean Cargo
Fred’s Ocean Cargo – Customs Entry Process Flow
Ocean ISF Process Flow
Entry File Creation - Forwarder
Periodic Monthly Statement
Chapter 3 – Recordkeeping
Chapter 4 – Classification
Responsibility
Classification Resources
Classification Process
General Rules of Interpretation
Classification Documentation,
Chapter 5 – Appraisement of Imported Merchandise
Value Reconciliation
Resources for Appraisement
Chapter 6 – African Growth and Opportunity Act
AGOA Guidance
AGOA Textile Articles
AGOA Best Practice
AGOA Process Flow
Chapter 7 – Post Entry Activities
Post Entry Audits
Quarterly Procedure Audits
Prior Disclosure
Chapter 8 – Customs Trade Partnership Against Terrorism
Milestones in Fred’s C-TPAT Participation
Fred’s Employee C-TPAT Training
Key Fred’s C-TPAT Maintenance Activities
Chapter 9 – Staff Certifications and Training
Certifications and Licensure
Training
Chapter 10 – Reference Materials
Chapter 11 – Contact Information
United Customs and Border Protection
Customs Broker
Compliance Consultant Agency
Legal Counsel
Attachment
Organization Chart
Record Retention Schedule
Customs Entry Audit Checklist
AGOA Outline for Checklist
AGOA Checklist
AGOA Audit Process
Employee Affidavit Regarding Customs Compliance Manual
3
Chapter 1 – Introduction and Company Background
Background
The Modernization Act of 1993 (“Mod Act”) fundamentally altered the relationship between importers and Customs. The
Mod Act shifted the legal responsibility to the importer for declaring value, classification, and other information necessary
to assess the correct duty rate applicable to entered merchandise. The Mod Act also required importers to use reasonable
care to assure Customs is provided accurate and timely data. Finally, the Mod Act increased the maximum civil and
criminal penalties for negligent or fraudulent failure to comply with Customs regulations.
The purpose of this manual is to describe the processes and define those responsible to ensure compliance by Fred’s
Incorporated (“Fred’s Inc or Fred’s”) with the regulations and expectations of the United States Customs and Border
Protection (“Customs”).
Company Information
Tracing its history back to an original store in Coldwater, Mississippi opened in 1947, today Fred’s is headquartered in
Memphis, Tennessee and operates almost 700 discount general merchandise stores, including 22 franchised Fred’s Stores,
mainly across the southeastern states.
With a unique store format and strategy that combines the best elements of a discount dollar store, drug store and mass
merchant, Fred’s stores stock more than 12,000 frequently purchased items that address the everyday needs of its
customers. This merchandise includes nationally recognized brand name products, proprietary Fred’s label products, and
lower-priced, and off-brand products.
The company has two distribution centers, one in Memphis, Tennessee, and the other in Dublin, Georgia. Fred’s Inc
sources both domestically and internationally with the majority of the international consumer goods sourced from China
and Southeast Asia. Fred’s Inc has long standing relationships with all their vendors and has both Open Account and
Letter of Credit payment terms.
Company Organization
The Import Department has been established at Fred’s to serve as the first line of defense in ensuring compliance by the
company with international trade laws. Additionally, the responsibility for trade compliance begins with Fred’s senior
management and is an expectation for all associates involved in international shipments and transactions. The following
organization chart describes the placement of the Import Department in the organization.
4
Responsibility Matrix Responsibility Manager
Mr. Bruce Efird
Mr. Reggie Jacobs
Mr. Michael Feliciano
Additionally, Attachment A is an organization chart for the area of responsibility for Mr. Reggie Jacobs, EVP of
Distribution, Transportation and Corporate Services. The Chain of authority noted above is highlighted in yellow on the
attachment.
Company Import Compliance Policy
Fred’s Customs and International Trade Policy is defined to all company associates as follows1:
When importing products, information or technology, Fred’s will comply with applicable U.S. and other national laws,
regulations and restrictions. This includes compliance with all applicable tax and tariff laws and regulations. If in
doubt about the law, check with the Import Department or the Legal Department. All information you or Fred’s
agents provide government officials or agencies must be accurate and truthful.
1 Fred’s Incorporated – Code of Business Conduct and Ethics
Fred’s
CEO
EVP of
Distribution,
Transportation
& Corporate
Services
Director,
Import
Department
5
Purpose of Import Manual
The Import Manual has been published for the purpose of guiding Fred’s associates in ensuring the company is in
compliance with Customs laws and expectations. Additionally, the manual is intended to convey the high level of
importance Fred’s treats its responsibility to maintain compliance with Customs regulations. Further, more specific
details on individual task execution are documented in Desk Level Standard Operating Procedures (SOPs) designed to
give very specific guidance on completing Import Department Staff assigned responsibilities.
At no time should this manual over-ride Customs regulations or law or any other expectation of US government agencies
tasked with enforcing import law.
This manual will be updated as needed when new Customs regulations are issued or at a minimum, the manual will be
reviewed fully and updated in the 3rd
quarter of each year.
6
Chapter 2 – Import Process
Ocean Cargo
Fred’s routinely receives containerized ocean cargo from varies points of origin, mainly from Asia with the largest origin
ports being Yantian, Ningbo and Shanghai. The process has been defined by the flowcharts shown below that detail the
following aspects of our ocean entry activities with our service provider.
1. Overview of Entire Ocean Process
2. ISF process
3. Entry file creation process
The ISF, now in the phased enforcement period, requires the reporting of 10 data elements by importers at a minimum of
twenty four hours prior to cargo being laden on the vessel bound for the United States at the foreign port of lading.
Fred’s Ocean Cargo – Customs Entry Process Flow
Fred’s Import Staff monitors ETA revisions / Entry Timing / Exams
1. Assign Booking #
2. Create Electronic file
3. Identify P/C #s on shipment
4. Initiate Alerts
5. Create Download - Push
6. Log File – Pull
7. Pre Key entry
*See Entry File Creation for specific steps
Fred’s Import Ocean Shipment
Ex Asia Ports
Customs
Broker Entry
Process
Documents
sent to
forwarder
ISF
Transaction
US Customs
Entry to US
Customs
Ocean Cargo
delivered to
Fred’s
Cargo
Examination
by US
Customs
10+2 Data Elements reported to US CBP 24
hours prior to cargo loading on US bound
vessel
* See ISF Process Flow for specific steps
7
Ocean – ISF Process Flow
Key
CBP Customs & Border Protection
CY Container Yard
EIR Equipment Interchange Receipt
FF Freight Forwarder
FI Fred’s Incorporated
ISF Import Security Filing
P/O Purchase Order
S/O Booking Confirmation
SSL Steam Ship Line
SI Shipper Instructions
ISF Importer Required Data
1. Seller
2. Buyer
3. Importer of Record Number
4. Consignee Number
5. Manufacturer of Supplier
6. Ship to Party
7. Country of Origin
8. Commodity – HTSUS number
9. Container Stuffing Location
10. Consolidator
FI transmits PO
information via
EDI to FF
FF contacts
vendors to make bookings as per
PO information
received via EDI
by FI
SSL allocates space, FF releases
S/O to
vendor/shipper
SI Cutoff
Container
loaded and SI
submitted to FF
to catch planned
vessel.
Avg. 14 Days Prior to Sailing
FF team
creates an
export file
and contacts
SSL.
Avg. 7 Days Prior to Sailing
CY Cut-off
Accurate
Data for
ISF
ISF Data
transmitted to CBP
CBP
message(s)
returned to
FF
Inaccurate or
incomplete data
returned to FI
for correction
Yes
Avg. 2 Days Prior to Sailing
No
Vendor/Shipper
takes S/O to
terminal to obtain
EIR, container
picked up and
taken to factory for
loading.
Avg. 4 Days Prior to Sailing
FF compares data
to internal system edits to ensure
accurate ISF
transaction
8
Entry File Creation -Forwarder
Shipping Documents from Fred’s vendors/shipper’s to Service Provider:
Commercial Invoice(s)
Packing List(s)
Certificate of Origin (if applicable)
Notification of shipment
Departure from last foreign port
Pre-Notification
- Electronic Notification (EDI)
- Arrival Notice / Docs
- Update log w/n 24 hrs
- Report Visibility
Entry Process
- Review DLSOP
- Request missing documents
- Key data w/in 24 hrs
- Transmit entry with I.T.
Dispatch & Delivery
- Verify freight release
- Confirm arrival
- Dispatch trucker
- Delivery updates w/in 4 hrs
Inaccurate or
incomplete data
contact Fred’s
Import Team for
assistance
Billing
- Invoice w/in 1 hour of entry
- Verify rates prior to invoice
- Send invoice w/in 24 hours
Document Receipt
- Request Docs w/in 48 hrs
- Receive docs w/in 7 days
- Verify all documents
- Update receipt w/in 24 hrs
9
Periodic Monthly Statement
Beginning in February 2006, Fred’s took advantage of the Periodic Monthly Statement (P.M.S) offered by way of the
Automated Commercial Environment. Fred’s utilizes the default preliminary and final statement dates in ACE. The
preliminary statement date will be the 11th working day of each month and the final statement date (due date) will be the
15th working day of each month. The Import Department Team will communicate the necessary funding amounts to the
treasury function of the General Ledger Team (Fred’s Accounting Department) each month. The General Ledger Team
will monitor the appropriate bank account for the ACH debit each month by CBP.
CBP has published the following 2011 dates for Periodic Monthly Statement:
Month Preliminary Final
January 18-Jan-11 24-Jan-11
February 15-Feb-11 22-Feb-11
March 15-Mar-11 21-Mar-11
April 15-Apr-11 21-Apr-11
May 16-May-11 20-May-11
June 15-Jun-11 21-Jun-11
July 18-Jul-11 22-Jul-11
August 15-Aug-11 19-Aug-11
September 16-Sep-11 22-Sep-11
October 18-Oct-11 24-Oct-11
November 16-Nov-11 22-Nov-11
December 15-Dec-11 21-Dec-11
CBP expects the trade community to contact the Revenue Division for any questions regarding periodic payment.
Specifically, the Periodic Payment Help Desk can be reached at phone number 317-614-4545 or via email at
Automated Commercial Environment (ACE)
The Automated Commercial Environment (ACE) is the commercial processing system in development by CBP and
currently operational for a number of capabilities. During 2012 Fred’s established an ACE portal account and has sought
opportunities to take advantage of the functionality offered by the system.
The Import Compliance Specialist will serve as the Point of Contact for the account. The Director of Imports will be
responsible to ensure that access is removed for any employment that is terminated.
The contact for assistance with the ACE Portal is by telephone number 866-530-4172.
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Chapter 3 –Record-keeping
Fred’s will maintain records for import transactions in accordance with the expectations and regulations of US Customs
and any other government agency involved in a given import. Specifically, Fred’s will maintain the required records
provided by the “(a)(1)(A) list² in a manner described by 19 CFR § 163.4. Thus, records will generally be maintained for
a period of five years from the date of the entry or the activity that required record creation. Exception to the normal
record retention period would be litigation hold or some un-resolved activity related to a given transaction (i.e. Prior
Disclosure).
The Import Compliance Specialist along with the Director of Imports provides specific US Customs record retention
instructions and schedule to the Import Team. These instructions allow our outside vendor, Cook’s Mobile Shredding
Services, Inc (“CMSS”), to destroyed import related documentation based on the required record retention schedule. The
CMSS is located separate from the Fred’s Inc facility in Memphis, TN.
Record retention period (see Attachment B) specific to Fred’s import transactions will be maintained on the Fred’s Record
Retention Index located on the Fred's I - Drive Folder: Imports/Record Retention.
The overall Fred’s Record-Keeping policy and operating procedures are defined by Fred’s Inc Code of Business Conduct
and Ethics located in the Investor Relation section on Fred’s Inc website.
Month and Year of Time of Entry Month and Year of destruction
Financial Records
2007 2007 2007 2007 - 2008 2012 2012 2012 2012 - 2013
Record Type Retention Period (Years) Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan
Invoice for services rendered 5 yrs from date of invoice
Business Records
Record Type Retention Period (Years) Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan
Right to Make Entry - Bill of Lading 5 yrs from date of entry
Commercial Invoice and any revised Commercial Invoices
5 yrs from date of entry
Packing list and any revised Packing List
5 yrs from date of entry
Certificate Of Origin 5 yrs from date of entry
CF 19 - Protest 5 yrs from date of entry
CF 28 - Request for Information 5 yrs from date of entry
CF 29 - Notice of Action 5 yrs from date of entry
CF 3461 - Entry - Immediate Delivery
5 yrs from date of entry
CF 7501 - Entry Summary 5 yrs from date of entry
CF 7512 - Transportation Entry and Manifest of Goods subject to CBP
Inspection and Permit 5 yrs from date of entry
Post Entry Amendments 5 yrs from date of entry
African Growth Opportunity Act (AGOA)
5 yrs from date of entry
Textile Declaration 5 yrs from date of entry
Anti-Dumping Duty (ADD) 5 yrs from date of entry
Countervailing Duty (CVD) 5 yrs from date of entry
11
Chapter 4 – Classification
Fred’s will utilize reasonable care in all activities related to the classification of imported goods. Any errors discovered in
the classification of merchandise will be immediately corrected and an investigation will be conducted to determine the
root cause of the classification mistake. Detailed records will be maintained of all classification activity in order to
support the resources and information utilized to arrive at the appropriate classification for a given part.
Responsibility
The associate responsible for classification in the Import Department has the appropriate authority to interact with the
necessary department(s) in the organization to ascertain the information to classify imported goods. Some of the key
groups at Fred’s that are called upon for the technical expertise in the classification process include:
Merchandising Department
o Homelines
o Softlines
o Hardlines
o Consumables
Sourcing
All classification work completed outside of the Import Department will be reviewed by the Import Compliance Specialist
for accuracy. No classification(s) will be applied to an import without approval from the Import Compliance Specialist.
In the event that the Import Compliance Specialist does not agree on the appropriate tariff number, the item will be sent to
the Director of Imports for further review and decision. The following flow chart identifies responsibility for
classification at Fred’s.
Classification Resources
The following resources are frequently utilized in the classification process: 1. Harmonized Tariff Schedule of the United States (HTSUS) – (www.usitc.gov)
2. Court of International Trade Cases (www.cit.uscourts.gov)
3. US Court of Appeals for the Federal Circuit Cases (www.cafc.uscourts.gov)
4. US Supreme Court Cases (www.supremecourtus.gov)
5. Informed Compliance Publications (www.Customs.gov)
6. Customs Rulings Online Search System (CROSS) – (www.Customs.gov)
7. Industry Publications
8. Industry Specific Dictionaries
9. Dictionary (Webster’s)
Part Classified
for Import
Import Staff
Classifies Part
Import
Compliance
Specialist Reviews
Classification
Director of Imports
Reviews
Classification
New Fred’s Part
12
Classification Process
Fred’s utilizes the following steps based on the appropriate use of the HTSUS to classify merchandise.
New Fred’s Part
Fred’s Part Classified
for Imports
Step
1
Parts Rule
EO Part of Article Other
Step
2
Set / Mixture / Composite Rule
Set if no
Composite Essential if yes
Mixture EO Character
Last in Tariff
If yes
Classify
Step
3
Incomplete / Unfinished Rule
Substantially Complete Parts Rule
Step
4
Packing / Packaging Rule
Usual or Ordinary Classify with Goods
Fitted Container Classify with Goods
Durable, not Fitted Classify Separately
Step
5
Determine location where goods are classified
Section and Chapter Notes will define, redirect, exclude or include goods
USHTS is comprised of Chapter, Heading, Sub-Heading, Sub-subheading and statistical number
Step
6
1. 3. 2. 4.
EO Nominee Most Specific Most Akin Other
Classify in subheadings of their own handling, according to the terms of subheading and subheading
notes, according to GRIs 1-5, section notes and chapter notes.
13
General Rules of Interpretation
The following General Rules of Interpretation (GRIs) governed tariff classification and are depicted through the flowchart
above. These rules are found in the HTSUS.
The table of contents, alphabetical index, and titles of sections, chapters and sub-chapters are provided for ease of
reference only; for legal purposes, classification shall be determined according to the terms of the headings and any
relative section or chapter notes and, provided such headings or notes do not otherwise require, according to the
following provisions:
(a) Any reference in a heading to an article shall be taken to include a reference to that article incomplete or
unfinished, provided that, as entered, the incomplete or unfinished article has the complete or finished (or falling to be
classified as complete or finished by virtue of this rule) entered unassembled or disassembled.
(b) Any reference in a heading to a material or substances shall be taken to include a reference to mixtures or
combinations of that material or substance with other materials or substances. Any reference to goods of a given
material or substance shall be taken to include a reference to goods consisting wholly or partly of such material or
substances. The classification of goods consisting of more than one material or substances shall be according to the
principle of rule 3.
When by application of rule 2(b) or by any other means, goods are, prima facie, classifiable under two or more
headings, classification shall be effected as follows:
(a) The heading which provides the most specific description shall be preferred to headings providing a more general
description. However, when two or more headings each refer to part only of the materials or substances contained
in mixed or composite goods or to part only of the items in a set put up for retail, those headings are to regarded
as equally specific in relation to those goods, even if one of them given a more complete or precise description of
the goods.
(b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put
up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of
the material or component which gives them their essential character, insofar as this criterion is applicable.
(c) When goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which
occurs last in numerical order among those which equally merit consideration.
Goods which cannot be classified in accordance with the above rules shall be classified under the heading appropriate
to the goods to which they are most akin.
In addition to the foregoing provisions, the following rules shall apply in respect of the goods referred to therein:
(a) Camera cases, musical instrument cases, gun cases, drawing instrument cases, necklace cases and similar
containers, specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and
entered with the articles for which they are intended, shall be classified with such articles when of a kind normally
sold therewith. This rule does not, however, apply to containers which give the whole its essential character;
(b) Subject to the provisions of rule 5(a) above, packing materials and packing containers entered with the goods
therein shall be classified with the goods if they are of a kind normally used for packing such goods. However,
this provision is not binding when such packing materials or packing containers are clearly suitable for repetitive
use.
For legal purposes, the classification of goods in the subheadings of a heading shall be determined according to the
terms of those subheadings and any related subheading notes and, mutates mutandis, to the above rules, on the
understanding that only subheadings at the same level are comparable. For the purposes of this rule, the relative
section, chapter and subchapter notes also apply, unless the context otherwise requires.
14
Classification Documentation
The following information will be documented for each item classified for importation:
Part Number or Item Number
Part Description
Invoice description Clarification
HTSUS
Early / late triggers
Simple / Complex
GRI
Legal resource
Legal Citation
Binding Ruling
Reviewed By
Date
Classification Requested by
The record of this data will be maintained on the I-Drive folder: Imports/Customs Compliance & Regulatory
Information/Compliance Manual/Classification Documentation.
15
Chapter 5 – Appraisement of Imported Merchandise
Transaction Value is typically the proper basis of appraisement for Fred’s importations. For any importations that are not
appropriately appraised with transaction value, Fred’s will ensure that the appropriate method of appraisement is applied
to the subject transaction. The alternate methods of appraisement to transaction value follow and are applied in such
order:
Transaction Value of Identical Merchandise (19 CFR § 152.104)
Transaction Value of Similar Merchandise (19 CFR § 152.104)
Deductive Value (19 CFR § 152.105)
Computed Value (19 CFR § 152.106)
Value if other values cannot be determined or used (19 CFR § 152.107)
The primary responsibility for appropriate appraisement of imported merchandise is held by the Import Compliance
Specialist; however, routine discussion is required with upper management of the Merchant’s and Sourcing Departments
to ensure the capture and reporting of all transactions affecting the appraisement of imported merchandise.
Value Reconciliation
Value reconciliation will be the exclusive mechanism utilized by Fred’s to make post importation adjustments to the
entered value of merchandise. The exception would be a clerical error that resulted in an inappropriate declaration and a
post entry amendment (PEA) or other appropriate mechanism for such correction.
An Importer Trade Activity Request (ITRAC) will be placed on an annual basis to the Office of International Trade
Analytical Development Division at Customs Headquarters to receive historical import data. This data will be utilized in
conjunction with historical data from the Customs broker to ensure that all entries requiring reconciliation are identified
and subsequently closed for value reconciliation. The annual request for ITRAC data will be placed each year between
January 15 and 31, upon reviewing the request and receiving the signature of Reggie Jacobs, EVP of Distribution,
Transportation, and Corporate Services. The ITRAC request is made under the Freedom of Information Act (“FOIA”)
and requires the signature of a company office.
16
Resources for Appraisement
The following resources are available at the US Customs and Border Protection website to assist in the appraisement of
imported merchandise when applicable:
Informed Compliance Publication: Customs Value
Informed Compliance Publication: Customs Valuation Encyclopedia
Importing into the United States – A Guide for Commercial Importers
Automated Commercial System (ACS) Reconciliation Prototype. A guide to Compliance
In addition to these specific resources, there are numerous value related rulings and advice posted to the CROSS website
to use as reference in appraisement research.
17
Chapter 6 – African Growth and Opportunity Act (AGOA) Technical Information for Pre-Assessment Survey (TIPS)
The purpose of this document is to provide guidance in performing a Pre-Assessment Survey (PAS) of the Fred’s internal
control for articles entered for preferential treatment as products of the African Growth and Opportunity Act (AGOA) and
evaluating the results.
Generally Accepted Government Auditing Standards require the PAS team to obtain a sufficient understanding of internal
control to plan the audit and determine the nature, timing, and extend of tests to be performed.
The guidelines and terms in this document are based on Assessing Internal Controls in Performance Audits; GAO/OP-
4.1.4, published by the United States General Accounting Office, Office of Policy, September 1990, and the American
Institute of Certified Public Accountants Statement on Auditing Standards No. 78.
AGOA Guidance
Title I of the Trade and Development Act of 2000 (Public Law 106-200) entitled the AGOA. Codified at 19 U.S.C. 3721
through 3724, AGOA is a special trade program authorizing the president to extend certain trade benefits for eligible
articles of designated beneficiary countries (BCs) in sub-Saharan Africa.
General Note 16 of the Harmonized Tariff Schedule of the United States (HTSUS) designates the BCs eligible to claim
preference under AGOA. The merchandise subject to AGOA preference appears as “free or at a reduced rate of duty” by
HTSUS number in the HTSUS “Special” Rate of Duty Sub-column followed by the symbol D in the parenthesis. The
African Growth Preference is claimed on the imported good by using the letter D in the Special Program Indicator field of
the Automated Commercial System (ACE) database. AGOA textile/apparel and non-textile article requirements are in
separate sections of 19 CFR Part 10. For purposes of this technical guide the term textile will include textile and apparel
covered by the AGOA regulations. In addition to the General Note and the Customs regulations there is a Customs
Informed Compliance Pamphlet for AGOA dated May 2001.
Additional guidance may be found in:
C.S.D. 85-25 (double substantial transformation)
Ruling 556193, dated 12/23/91 (dual-sourcing)
Ruling 557087, dated 7/22/93, T.D. 78-399, and C.S.D. 80-208 (unallowable general and administrative costs)
Ruling 559010, dated 3/14/96 and T.D. 91-7 (treatment of components in sets).
The Trade Act of 2002 (“the Act”) was signed by President Bush on August 6, 2002, and substantially expands
preferential access for imports from beneficiary Sub-Saharan African countries by modifying certain provisions of the
African Growth and Opportunity Act (AGOA).
The Act clarifies and narrowly expands the trade opportunities for Sub-Saharan African countries under AGOA and
encourages more investment in the region. AGOA enhancements include revisions requested by many Sub-Saharan
African countries. These enhancements maximize the benefits of AGOA. Auditors must obtain current information on
AGOA provisions for imports after August 6, 2002.
AGOA Textile Articles
The eligibility requirements for AGOA textile articles (as defined in 19 CFR 10.212) are found in 19 CFR 10.211 through
10.217. Section 10.213 (a)(10) through (a)(10) describes those eligible textile articles and the specific rules that are
considered for AGOA preference. Section 10.213(b) lists the additional special rules for component materials. To qualify
for preferential treatment AGOA textile and apparel, articles must meet the following requirements:
The imported goods must come to the United States directly from the sub-Saharan beneficiary country: the direct
shipment requirements are in section 10.178a (e)(4) that refers to the GSP provision of section 10.175.
The imported goods must meet the country of origin criteria as stated in section 10.178a (e)(2). This section
defines the qualified merchandise as either: a) wholly the growth, product or manufacture of the beneficiary
country: or b) transformed into new or different article that has been grown, produced or manufactured in a
18
beneficiary country. Section 10.178a (e)(5) refers to the GSP provision of section 10.173.
The imported goods must meet the value content requirements of section 10.178a (d)(4); the sum of materials and
direct cost of processing must represent not less than 35% of the goods’ appraised value at the time it is entered.
AGOA Best Practice
Fred’s Incorporated Imports goods that is eligible for duty-free treatment under the African Growth Opportunity Act
(AGOA). To support the duty free importation of goods in accordance with the AGOA Agreement and to ensure that
reasonable care is exercised by Fred’s and its suppliers, Fred’s has implemented a corrective action plan. This corrective
action plan includes continuing to collect and retain documentation to support AGOA eligibility and engaging a third-
party, Expeditors and Tradewin LLC, to implement a best practices third-party review of Fred’s compliance with the
AGOA Special Trade Program. This review will include the following:
Sample Selection of 10% of the goods imported under AGOA
A complete review of the documentation supporting the selected sample population
Documented review findings and recommendations.
The review periods extend to more than one fiscal quarter. Entry selections for the review process are chosen by
Randomizer and are profiled by the following:
AGOA Audit Process Steps:
Request Entry Universe from Fred’s
Select Sample 10% Review Population
Request Entry Packet and AGOA support Documents from Fred’s
Review AGOA Support Documentation for:
o Completeness
o Compliance with AGOA program
Document Review Findings
Included in this manual is an example of the AGOA Audit process (see Attachment F) along with qualifying questions
and findings.
19
AGOA Process Flow – Overview
Fred’s sources goods from Durban and Cape Town South Africa which qualify for the African Growth and Opportunity
Act (AGOA).
The following flowchart details the internal process to determine that the imported merchandise qualifies for AGOA:
Start
Step
1
Step
2
Oracle FOB DUR Report Extract into excel Sort by arrival date, copy & paste Save data on shared drive
Documents Received by LC# or AO# AGOA Outline for Checklist (Attachment D) AGOA Checklist (Attachment E) Checklist completed Checklist placed with AGOA documentation
Documents missing, contact vendor immediately
Step
3
Documents Filed Away by LC# or AO# Filed Cabinet Draw Identification 1-1, 1-2, 1-3, 1-4, etc 2-1, 2-2, 2-3, 2-4, etc 3-1, 3-2, 3-3, 3-4, etc 4-1, 4-2, 4-3, 4-4, etc Documentation location recorded on AGOA Spreadsheet Located on the Shared I Drive: Imports/Customs Compliance & Regulatory Information
1-1 __
1-2 __
1-3 __
1-4 __
2-1 __
2-2 __
2-3 __
2-4 __
20
Chapter 7 - Post Entry Activities
Fred’s will utilize post entry audits of Customs entries to ensure a high level of compliance with Customs regulations and
to ensure that established internal controls are functioning as designed to result in accurate transaction.
In addition, Fred’s will remain vigilant for requests coming from Customs in the form of CF-28m CF-29s. These requests
will be brought to the attention of the Import Director and investigated with a sense of urgency. The Fred’s Import
Compliance Specialist will monitor the due dates of all requests from Customs and ensure a timely response.
Post Entry Audits
Fred’s will conduct a “cradle to grave” audit in the following manner each month representing a sample of 5% of all
entries.
Ocean Entries – 1 entry per month (6 average total per month)
Monthly samples will consist of entries with the next to last digit of the entry number of 6. Once the entry numbers for
the audit sample have been determined the checklist included as Attachment C will be utilized to document the results of
each audit.
The goal for an acceptable level of compliance is designed to match the following levels prescribed by the United States
Customs and Border Protection, Focused Assessment Program².
Classification – Dollars Compliant ≥ 99%
Valuation – Value Variances ≤ $10,000,000 or ≤ 1%
Non-Classification sampling Areas – Dollars Compliant ≥ 99%
All audit results will be saved electronically on the I Drive; I:\IMPORTS\Customs Compliance & Regulatory
Information\Post Entry Audits and any issues discovered will be elevated to the Director of Imports review and counter
measure.
Quarterly Procedure Audits
The Import Compliance Specialist or designated import team member will audit the following compliance tools on a
quarterly basis and report findings to the Import Compliance Specialist and the Director of Imports:
Classification – 3 newly classified parts will be selected for review against established procedures
Classification Assistance (TradeFlow) – 5 random SKU’s will be selected for review of recorded information
Commercial Invoice Number to Entry – 3 random entries will be chosen to compare invoices shipped to those
numbers recorded on the entry.
Prior Disclosure
The United States Code of Federal Regulations (19 CFR § 162.74) provides a mechanism for importers to bring violations
to the attention of Customs prior to their knowledge or initiation of an investigation in exchange for reduced penalties.
Fred’s will utilize this mechanism when a discovery is made that is a violation of import law.
All Fred’s employees are expected to bring forward any evidence or suspicion of error in import transactions to the
immediate attention of Import Compliance Specialist or the Director of Imports. The information will be reviewed and
advice will be sought from both internal and external legal counsel if warranted.
Fred’s will take great care if required to submit a complete and accurate disclosure to Customs. In addition to the
resources noted above, an Informed Compliance Publication is available on the cbp.gov website The ABC’s of Prior
Disclosure.
21
Chapter 8 – Customs – Trade Partnership Against Terrorism
The C-TPAT program has emerged as a critical program of Customs in recent years and Fred’s has embraced the critical
need for the trade’s full participation in protecting international supply chains. The importance of this program combined
with the integral nature of the C-TPAT procedures warrants a summary of Fred’s activity in this manual.
Milestones in Fred’s C-TPAT Participation
Fred’s has adjusted its resources in recent years to accomplish the following activities:
Signed MOU – July 2004
Accepted as C-TPAT partner – June 2004
Domestic validation – August 2007
Foreign validation – February 2006
Validation letter received – May 2006
Complete C-TPAT Security Link Portal – October 2006
August 2007 Notified Tier status has been raised to Tier 2.
Fred’s Employee C-TPAT Training
In accordance with the expectations of C-TPAT importers, Fred’s is proud of our efforts to bring C-TPAT awareness to
all employees and contractors who come to work at the Memphis facility each day. Several of our main programs to
accomplish this:
1. Direct training for all newly hired employees during Orientation. Either the Import Compliance Specialist or the
Director of Imports provides training directly to all new-hire employees at Fred’s and emphasizes the role each
individual plays in remaining vigilant to anomalies they encounter during the course of their work.
2. Awareness training for all Fred’s staff and on-site contractors provided twice a year.
3. All on-site contractors, security staff and those issued permanent visitor privileges are required to undergo Fred’s
orientation that includes briefings on C-TPAT awareness and is conducted by either the Import Compliance
Specialist or the Director of Imports in conjunction with Security staff.
Key Fred’s C-TPAT Maintenance Activities
In our effort to maintain Fred’s accomplishments in the program and continually improve our security efforts, the
following are critical activities to ensure leadership in the area:
Regular communication with Fred’s security staff.
Prompt follow-up by both security staff and the Import Department on reports of potential security anomalies or
discrepancies (i.e. missing seal).
Yearly attendance at the C-TPAT Conference to provide education on best practices, stay abreast of the program
expectations and benchmark with fellow partners on their experience.
On-going communication with suppliers to encourage C-TPAT program membership and confirm adoption of C-
TPAT approved security procedures.
22
Chapter 9 – Staff Certification and Training
Maintaining a qualified, knowledgeable and compliance minded Import staff is a critical component to Fred’s success in
meeting the expectations of Customs. An ongoing commitment to education is important to keep up to date with the
constantly changing environment of Customs regulations, expectations and programs.
Certifications and Licensure
One member from the Import Department will attend the on-line Certified Customs Specialist³ (CCS) beginning January
2013.
Amy Tutor – January 2013.
Upon Amy’s successful completion of the curriculum, Michael Feliciano will attend the on-line course followed by Tera
Shockley.
There are currently no Fred’s employees with their Customs license. The Director and the Import Compliance Specialist
will work diligently to successfully pass the exam and obtain their Customer license.
Training
Fred’s will continually seek opportunities for Import Staff to improve their Customs knowledge and all staff will be
required to meet the annual continuing education requirements for maintenance of their individual CCS certification. The
NCBFAA education Director transcripts will be the primary tool utilized to track the training progress and history of each
employee.
Additionally, all Import staff’s training is documented on the internal hard drive, in the following folder:
I:\IMPORTS\Training. Any Import staff who attends an off-site or government sponsored training are expected to provide
proof of attendance and ensure training is recorded in the system by the department training representative.
The Fred’s annual review process will be the opportunity for the Director of Imports to discuss progress with the
employee on the annual training requirements. At each face-to-face meeting conducting during the annual review,
training progress and planning will be a topic of discussion between the employee and management.
23
Chapter 10 – Reference Material
Fred’s Incorporated will use a number of Customs Informed Compliance Publications (ICP) to assist in complying with
the Customs Laws and Regulations. These ICPs can be found on Customs’ website at www.cbp.gov. Following are some
of the ICPs available which Fred’s consults:
Customs Value
Customs Valuation Encyclopedia
Tariff Classification
Internal Combustion Piston Engines
Vehicles, Parts and Accessories
Reasonable Care
Recordkeeping
Rules of Origin
In addition to ICPs, Fred’s Import Compliance Group uses the following publications available for reference both in hard
copy and on-line:
Code of Federal Regulations, title 19, parts 1 to 199 (www.gpoaccess.gov/cfr/index.html)
Harmonized Tariff Schedule of the United States (www.usitc.gov)
Explanatory Notes (www.Customsinfo.com)
In conjunction with the above-mentioned tools, Fred’s utilizes CROSS (Customs Ruling Online Search System) along
with a subscription service called Customs Info (www.customsinfo.com). Both CROSS and Customs Info are searchable
databases of Customs rulings, Fred’s consults the Rulings found in these sources for guidance in classification of like
parts. Further, Fred’s subscription to International Trade today published by Broker Power, Inc. provides a daily forum
for updates on Customs activity, new and pending regulations, and general international trade news.
24
Chapter 11 – Contact Information
The following information serves as a reference for critical organizations supporting Fred’s Import Department activities.
United Customs and Border Protection
CBP Port of Entry – Memphis
Port Code 2006
Port Director: Mr. Martin Childs 3150 Tchulahoma Road
Suite 1
Memphis, TN 38118
Phone: General (901) 544-0291
Commodity Team Assignments
o Supervisor, Import Specialist: Judy Watkins 901-544-0299
o Team Leaders: Nancy Bomar 901-544-0605, Robert Bowman 901-544-0603
Chapters: 72-84
CST-508
o Iron, steel, copper, nickel, aluminum, lead, zinc, tin, other base metals and articles thereof
(Chapter 72-81)
o Tools, implements, cutlery, miscellaneous articles of base metals (Chapters: 82-83)
o Nuclear reactors, boilers, generators, turbines, engines, motors, pumps, compressors,
fans, air conditioners, scales, hand tools, pulleys, molds, valves, bearings, machinery and
appliances (Chapter 84)
o Supervisor, Import Specialist: Vivian Collins 901-544-4324
o Team Leader: Maria Jackson 901 544-0604
Chapters: 1-40, 44-49, 68-71, 91-92, 97
CST-510
o Live animals, animal products (Chapters 1-5)
o Vegetable products (Chapters 6-14)
o Animal and vegetable fats and oils (Chapter 15)
o Prepared foodstuffs; Beverages, spirits and vinegar; Tobacco and tobacco substitutes
(Chapters 16-24)
o Mineral products (Chapters 25-27)
o Products of the chemical or allied industries (Chapters 28-38)
o Plastics and articles thereof; Rubber and articles thereof (Chapters 39-40)
o Wood, cork and straw; Articles thereof (Chapters 44-46)
o Wood pulp, paper, printed matter (Chapters 47-49)
o Articles of stone, plaster, cement, asbestos, mica or similar materials (Chapter 68)
o Ceramic products (Chapter 69)
o Glass and glassware (Chapter 70)
o Pearls, precious and semi-precious stones, precious metals, metals clad with precious
metal and articles thereof; Imitation jewelry; Coins
(Chapter 71)
25
o Clocks and watches and parts thereof (Chapter 91)
o Musical instruments; parts and accessories of such articles (Chapter 92)
o Supervisor, Import Specialist: John Gerace 901-544-0602
o Team Leaders: Lori Kreidermacher-Carter 901-544-0608, Eddie Griffin 901-544-0609
Chapters: 41-43, 50-67, 90, 94-96
CST-512
o Raw hides and sins, leather, fur skins and articles thereof; Saddlery and harness; Travel
goods, handbags and similar containers (Chapters 41-43)
o Textiles, wearing apparel and textile articles (Chapters 50-63)
o Footwear and headgear (Chapters 64 & 65)
o Umbrellas, walking sticks, seat sticks, whips, riding crops and parts thereof (Chapter 66)
o Feathers, down and articles thereof; Artificial flowers; Wigs (Chapter 67)
o Optical, photographic, cinematographic, measuring, checking, precision, medical or
surgical instruments and apparatus (Chapter 90)
o Brooms, brushes, pens, pencils and miscellaneous articles, furniture, mattresses, quilts,
pillows, lamps and lighting articles; Festive articles; Toys, games and sports equipment
(Chapters 94-96)
o Supervisor, Import Specialist: John Carpenter 901-544-0286
o Team Leaders: Marcelo Mancheno 901-544-0447, Valetta Lacy 901-544-0623
Chapters: 85-89, 93
CST-514
o Electrical machinery and equipment and parts thereof; Sound recorders and reproducers,
television image and sound recorders and reproducers, and parts and accessories of such
articles (Chapter 85)
o Railway or tramway locomotives, rolling-stock and parts thereof; Railway or tramway
track fixtures and fittings and parts thereof; Mechanical (including electro-mechanical)
traffic signaling equipment of all kinds (Chapter 86)
o Automobiles, motorcycles, trucks, tractors, trailers, bicycles, ATVs, hand trucks and
other vehicles; Parts and accessories thereof (Chapter 87)
o Aircraft, spacecraft, and parts thereof (Chapter 88)
o Arms and ammunition; Parts and accessories thereof (Chapter 93)
o Supervisor, Entry Specialist: David Gault 901-544-0295
American Goods Returned (9801) Entry Department
Government Entries (9808) Entry Department
Mr. Kevin Haggerty – C-TPAT, Supply Chain Security Specialist
United States Customs and Border Protection
726 Exchange Street
Suite 400
Buffalo, NY 14210
[email protected] Phone: (716) 565-3216
26
CBP Port of Entry – Long Beach, California
Port Code 2704 Port Director: Todd A. Hoffman
301 E Ocean BLVD
Suite 1400
Long Beach, CA 90802
Phone: General (562) 366-5555
Phone: Broker Management Office (562) 366-5404
Phone: Exam Team (310) 971-2244
CBP Port of Entry – Savannah, Georgia
Port Code 1703 Port Director: Ms. Lisa Beth Brown
1 East Bay Street
Savannah, GA 31401
Phone: General (912) 447-9400
Phone: Entry Branch (912) 447-9410
Phone: Import Specialist (912) 447-9420
Customs Broker
Expeditors International of Washington, Inc
5395 Distriplex Farms Drive
Memphis, TN 38141
Phone: 901-362-9771
Matt Littleton – District manager – [email protected]
Michelle Lashlee – Brokerage Manager – [email protected]
Justin Bender – Brokerage Team Lead Agent, Fred’s Account – [email protected]
Ashley Watson – Brokerage Agent, Fred’s Account – [email protected]
Charles Norwood – Account Manager – [email protected]
Compliance Consultant Agency
Expeditors, Tradewin LLC – Consultant Assigned:
Shelley Mcllwain
Senior Consultant
2508 N. Marine Drive
Portland, OR 97217
Legal Counsel
Mr. Bradley D. McAdory, Esq.
Vice President and Assistant General Counsel
4300 New Getwell Road
Memphis, TN 38141
Phone: (901) 238-2720
27
Attachment A Back to Responsibility Matrix
28
Attachment B Back to Record Keeping
Record Retention Schedule
Fred’s will maintain records for import transactions in accordance with the expectations and regulations of US Customs
and any other government agency involved in a given import. Specifically, Fred’s will maintain the required records
provided by the “(a)(1)(A) list² in a manner described by 19 CFR § 163.4. Thus, records will generally be maintained for
a period of five years from the date of the entry or the activity that required record creation. Exception to the normal
record retention period would be litigation hold or some un-resolved activity related to a given transaction (i.e. Prior
Disclosure).
Documents related to any import transaction will be shredded off-site by a third party, Cook’s Mobile Shredding Services,
Inc (CMSS) during the fiscal year. Below are examples of documents to be shredded along with the specific destruction
schedule.
Month and Year of Time of Entry Month and Year of destruction
Financial Records
2007 2007 2007 2007 - 2008 2012 2012 2012 2012 - 2013
Record Type Retention Period
(Years) Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan
Invoice for services rendered
5 yrs from date of invoice
Business Records
Record Type Retention Period
(Years) Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan Feb-Mar-Apr May-Jun-Jul Aug-Sept-Oct Nov-Dec-Jan
Right to Make Entry - Bill of Lading
5 yrs from date of entry
Commercial Invoice and any revised
Commercial Invoices
5 yrs from date of entry
Packing list and any revised Packing List
5 yrs from date of entry
Certificate Of Origin 5 yrs from date of
entry
CF 19 - Protest 5 yrs from date of
entry
CF 28 - Request for Information
5 yrs from date of entry
CF 29 - Notice of Action
5 yrs from date of entry
CF 3461 - Entry - Immediate Delivery
5 yrs from date of entry
CF 7501 - Entry Summary
5 yrs from date of entry
CF 7512 - Transportation Entry
and Manifest of Goods subject to CBP Inspection and Permit
5 yrs from date of entry
Post Entry Amendments
5 yrs from date of entry
African Growth Opportunity Act
(AGOA)
5 yrs from date of entry
Textile Declaration 5 yrs from date of
entry
Anti-Dumping Duty (ADD)
5 yrs from date of entry
Countervailing Duty (CVD)
5 yrs from date of entry
In an effort to minimize cost, all efforts will be made to consolidate import documentation needing to be destroyed
therefore, there may be some documents carried over from one quarter to another quarter.
29
Attachment C Back to Post Entry Audits
Customs Entry Audit Checklist
4
5
6
7
8
9
10
11
12
13
Accu rate MID Cod e s ee 7501 b ox 21 - com p are to m an u factu rer/s h ip p er on com m . In voice
com p are to C.A.T.P arty Relation s h ip d eclaration
Man ifes t Qty
HTS US (each 7501 lin e)
HTS rep ortin g q u an tity
Cou n try of Orig in
s ee 7501 b ox 31
com p are p art lis ted on in voice to C.A.T. or IMS d ata
com p are to d ata p rovid ed on com m ercial in voice
Com p are to com m ercial in voice an d C.A.T. (KD p arts lis t for ocean )
En tered Valu e
Foreig n Cu rren cy Con verted at Correct Exch an g e Rate
Match b etween AS N or P /C n u m b er on in voice to GP CS
com p are 7501 lin e to com m . In voice lin e an d com p are 7501 total to in voice total
en s u re n u m b er is record ed an d m atch ed to in voice in p acket from b roker
if com m ercial in voice is rated in foreig n cu rren cy, en s u re correct rate b y b roker
En s u re p arts lis t on com m ercial in voice are th os e ord ered on AS N or P /C
Com m ercial In voice Nu m b er / AS N Nu m b er
30
Attachment D Back to AGOA process flow
AGOA – African Growth Opportunity Act Outline for Checklist
In the event an import shipment qualifies for reduced/preferential treatment under the African Growth Opportunity Act,
each shipment must include the following documentation, to support the claim.
A. Raw Materials
Records demonstrating how, where and from whom raw materials, e.g. yarns, fabrics, knit-to-shape components,
trimmings and findings, were produced and obtained. All documents should be broken out by PO number.
purchase orders
invoices
bills of lading
receiving records
Export records and import records (if imported from another country into the claimed country of origin)
B. Cutting Records for products assembled from cut components:
manual cutting records maintained by the cutting section covering the entire cutting production run with respect to
the merchandise in question
employee time cards
C. Production Records:
a step-by-step summary of all production steps;
assembly or production records maintained on the factory floor by the production manager
individual workers’ daily assemble or production records
employee time cards
listing of the number of and types of machines available for and used in actual production
in-line inspection reports;
manufacturing factory profile
D. Subcontracted production work:
all applicable documents in items A through C above
all transfer documents showing movement of the freight from the subcontractor to the shipper or primary
contractor
proof of payment by the shipper or primary contractor for the work done.
E. Certificate of Origin:
certificate of origin – including an original signature and title
E. Transportation Documents:
forwarders cargo receipt or bills of lading to show the shipment was directly shipped from and AGOA country of
eligibility
31
Back to AGOA process flow
Attachment E Back to AGOA process flow
AGOA Checklist
Back to AGOA process flow
32
Attachment F
Back to AGOA Best Practice
AGOA Audit Process
Entry Number:
SKU:
Style:
PO:
Factory:
Manufacturer:
Qualification Question Findings Result
Is the article shipped directly from a
Beneficiary Country?
The Forwarder’s Cargo Receipt reflects that the cargo originated in Maseru, Lesotho was received on
(mmddyyyy) and was shipped from the Port of (Port of Export) and discharged in the port of Port of unladen (first) (city, state) on (mmddyyyy).
OK
What is the origin of the Materials and
Accessories? Is there documentary
evidence that the materials and accessories where delivered to the production location?
Pages (from-to) reflect fabric and accessories that are shipped from (Country) (material or accessory) and
(Country) (material or accessory) to (Country). Commercial invoices, packing list and BOLs are provided
as support. It is noted that proof of Customs entry into the Customs Territory of (Country) was or was not provided. The Vendor should be advised to add this documentation to the AGOA support documents.
OK
Is the article manufactured in a designated AGOA country?
Daily Cutting, Sewing and Packing documents are supplied (list which pages). An AGOA breakdown is supplied (list page). None of this is evidenced with payroll records or employee timesheets. The vendor
should be advised to add to their documentation provisions station/employee specific cutting and sewing records. In addition, Worker time cards and a schedule of payments to employees should also be gathered
and presented as support for the products AGOA qualification.
OK
Do records confirm the place of production,
number and type of machines used in
production and the number of workers employed?
The production record (list page) is issued by (name of person or company issuing the production record).
Additional records should be gathered by the factory to support production in the factory. This may
include an overview and or diagrams or pictures that reflect the factory size and layout, type and quantity of machines as well as the factory’s production capacity.
OK
Dates The goods in question were imported to the US on (mmddyyyy). Fabric and Accessories arrived in
(Country) between the dates of (mmddyyyy) and (mmddyyyy). Cutting and sewing records reflect production of: (dates mmddyyyy). The Forwarder took 32possession of the cargo on (mmddyyyy) and the
goods where entered into the Customs Territory of the US on (mmddyy).
OK
How do the articles qualify for AGOA?
What group?
AGOA textile Certificates of Origin issued by (name of person providing AGOA textile CO). Certify that
the imported articles qualify for the duty preference under the AGOA agreement as “Apparel assembled or knit-to-shape and assembled, or both, in one of more lesser developed beneficiary Countries regardless of
the country of origin of the fabric or yarn used to make such articles”. The Certificate is signed and
assigned an internal tracking number (example: 053130).
OK
Is the AGOA Textile Certificate of Origin
complete and reasonable?
AGOA Certificates of Origin appear to be complete and reasonably executed. OK
Recommendations Although the records reviewed support the AGOA claim, in the future, the vendor should be asked to retain and supply additional documents including: · Customs Entry Data that reflects the import of
fabric and accessories into the Customs Territory of (name of country and port). ·
Station and or employee specific cutting and sewing records. · Worker time cards and a schedule of payments to employees should also be gathered and presented as
support for the products AGOA qualification.
· An overview and or diagrams of pictures that reflect the factory size and layout, type and quantity of machines as well as the factory’s production capacity.
Back to AGOA Best Practice
33
Employee Affidavit Regarding Customs Compliance Manual
To: Import Director
With this affidavit, I certify that I have read and understand my obligations as outlined in Fred’s Import Manual.
Moreover, I understand that I will, to the best of my abilities, discharge my obligations as a Fred’s employee in
conformance with the requirements set forth therein.
Finally, I understand that this manual is confidential and proprietary, and that it is illegal for me to copy, disseminate or
otherwise reproduce this Manual without the express written permission of Fred’s Import Director.
__________________________________
(Signature)
__________________________________
(Printed Name)
__________________________________
(Title)
__________________________________
(Date)
